Design and Implementation of Comprehensive Tank Overfill Protection Program
Protecting human health and protecting the environment are essential requirements in today’s exploration and production (E&P), refining, and petroleum marketing workplaces (pipelines and terminal facilities). Preventing tank overfills at above-ground, atmospheric storage tanks is essential, for “overfills” and the attendant consequences (e.g., potential volitization and groundwater/soil contamination) pose significant risk to the safety of workers, surrounding communities, and the environment itself. Overfill incidents demonstrate the need, and urgency, for tank-overfill-protection (TOP) measures to be evaluated and, as determined, undertaken.
The design and implementation of a TOP program offers potential benefits for E&P in the environmental, human-health, community-welfare, and safety performance areas. E&P operations do not necessarily involve the numbers of atmospheric tanks that are involved in, say for example, midstream (pipeline) operations; nonetheless, safety and environmental contamination are issues of concern. There are common attributes of a comprehensive overfill protection that can be applied to E&P settings.
A TOP program for a large pipeline organization—consisting of more than 800 above-ground, atmospheric storage tanks (Class 1 through 3 liquids), at more than 90 facilities—was recently developed and implemented, and is currently undergoing its first year of compliance and assurance (C&A) evaluation. This program was comprehensive in nature, containing its own unique objectives and distinctives.
The comprehensive approach and method undertaken provided major benefits to the organization and successful and long-term implementation. Such benefits apply to large-scale programs and projects alike and include the following:
- Defined management philosophy/vision
- Organizational commitment
- Strengthened accountability
- Identification of systemic gaps
- Consistency in policies, standards, and operations
- Long-term C&A
The results yield enhanced operations, risk reduction, and improved safety, all of which were evidenced in the TOP program.
There are two aspects to an overfill-protection program. The first is the “programmatic” aspect, which addresses the various program features [i.e., policy development, standards and procedures, roles and responsibilities, program management (PM) functions] and various content features of the overfill policy to be implemented. The second aspect deals specifically with overfill equipment, to include equipment identification and related engineering, procurement, and construction (installation) activities, as well as any necessary electrical and instrumentation upgrades at a facility. The programmatic aspect, in a proactive and preventive sense, is deemed the most protective regarding tank-overfill events.
This paper addresses a “conceptual model” for an overfill-protection program, based on this recent industry example. Key portions of the programmatic and overfill-equipment aspects will be addressed.
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